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Consolidation: focussing on the formation tax return seminar paper


This paper covers the following topics:

  • client risk reviews
  • areas of ATO focus
  • challenge to market valuations
  • interest and penalty implications
  • whether the ACA is an opportunity to revisit past events
  • implications of the single entity rule and asset allocations.

Author profile:

Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016 Click here to expand/collapse more articles by Martin FRY.

This was presented at Corporate Tax Intensive: Corporate Tax Stakes.

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Selling the tax message

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Reasonably Arguable Position

Author(s):  Sue WILLIAMSON,  Monica JORDAN

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Consolidation: focussing on the formation tax return

Author(s):  Martin FRY

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Audit hotspots - lessons learned from corporate audits

Author(s):  Stef MASON

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